CODE OF CRIMINAL PROCEDURE

PROJECT REPORT
ON
Position of maintainence under live-in-
relationship : A critical study

SUBMITTED TO:

Mr. Mohammad Atif Khan

(Code of Criminal Procedure)

SUBMITTED BY:

Suhail Bansal
Roll no: - 173
Semester VII
Sec. - C

Date of Submission:- 21/08/2017

HIDAYATULLAH NATIONAL LAW UNIVERSITY, RAIPUR

 Declaration

I, Suhail Bansal, of Semester VII, Section C, declare that this project submitted to H.N.L.U.,
Raipur is an original work done by me under the able guidance of Mr. Mohammad Atif Khan,
Faculty of Criminal Procedure Code. The work is a bona fide creation done by me. Due
references in terms of footnotes have been duly given wherever necessary.

Suhail Bansal

Roll No. 173

 Code of Criminal Procedure

Acknowledgement

First and foremost I would like to thank Mr. Mohammad Atif Khan, faculty of Code
of Criminal Procedure, Hidayatullah National Law University Raipur, for creating
opportunities to undertake such a valuable project. He helped me in preparing the project
through his aura and by granting his precious time for consultation, discussion and giving
suggestions over this project. He had also helped me in improving the perception regarding
the study of topic in its vast resources and in broader way. He had cleared all doubts and
uncertainty towards this project. Therefore, I want to thank him, for all his efforts and
cooperation which he conferred to me.

I also owe my gratitude towards University Administration for providing me all kinds
of required facilities with good Library and IT lab. This helps me in making the project and
completing it. My special thank to Library Staff and IT staff for equipping me with the
necessary data and websites from the internet.

I would also like to show appreciation towards me because I had carried this project
work as a challenge and completed in due time. The topic of this project is much influencing
to me as it is trying to cross the scope of existing concept of law.

Suhail Bansal
Roll no: 173
Semester VII
Sec. - C

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 Code of Criminal Procedure

Table of Contents
Abbreviations Used ------------------------------------------------------- Page 1
Objective ------------------------------------------------------------------- Page 2
Methodology -------------------------------------------------------------- Page 2
Scope & Limitation ------------------------------------------------------- Page 2
Research Questions ------------------------------------------------------- Page 3
Synopsis -------------------------------------------------------------------- Page 4
Introduction ----------------------------------------------------------------- Page 6
Live-in-relationship & Maintenance ------------------------------------ Page 9
Maintenance recognized under Different Laws ----------------------- Page 10
Maintenance recognized under CrPC. ----------------------------------- Page 11
Courts on Maintenance in live-in-relationship ----------------------- Page 13
Criticism --------------------------------------------------------------------- Page 14
Self-Opinion ---------------------------------------------------------------- Page 15
Conclusion ----------------------------------------------------------------- Page 16
References ----------------------------------------------------------------- Page 17
o Books referred
o Statutes referred
o Cases referred
o Websites referred

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 Code of Criminal Procedure

Abbreviations Used

o acc. - Accessed
o AIR - All India Reporter
o AM - After Meridian
o attrib.adj. - Attributive(ly) Adjective
o colloq. - Colloquial(ly)
o Crl - Criminal
o CrPC - Code of Criminal Procedure
o Cr.PC - Code of Criminal Procedure
o Ed. - Edition
o esp. - Especial(ly)
o etc. - Et-Cetera
o HCs - High Courts
o Honble - Honourable
o i.e. - That is
o IST - Indian Standard Time
o no. - Number
o PC - Privy Council
o Pg. - Page
o S. - Section
o SC - Supreme Court
o SCC - Supreme Court Case
o W.P. - Writ Petition

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 Code of Criminal Procedure

Objective
The basic objective behind this project is to study and critically understand the
position of maintenance under live-in-relationship.

Methodology

The project is descriptive in manner. The notions of the project are completely related
to speculative study. The source of data for this project is secondary in nature i.e. including
books, articles, journals and online resources.

Scope and Limitation

This project work is carried out in the ambit of maintenance contemporarily

recognized under live-in-relationship by various judicial pronouncements, which entitles a
woman to get maintenance though she might not be a legally wedded wife. Further, these
project only deals with the concept of maintenance in live-in-relationship with regard to
Indian scenario.

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 Code of Criminal Procedure

RESEARCH QUESTIONS

This project deals with the topic Position of maintenance under Live-in-relationship:
A Critical Study. With reference to it following research questions had been framed, which
are discussed in this project.

Q1. What is the need of recognizing maintenance under live-in-relationship?

Q2. Why a woman only is entitle to get maintenance under live-in-relationship?

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SYNOPSIS
Live-in word means under oxford dictionary as attrib.adj. (Of sexual partner)
Cohabiting.1 And Relationship means 1 the fact or state of being related 2 colloq. a a
connection or association (enjoyed a good working relationship). b an emotional (esp. sexual)
association between two people. 3 a condition or character due to being related 4 kinship.2
Observing both the meaning, one common to both is sexual association. Therefore, when
relied upon the meaning of both the words and seen conjointly, primarily, it can be
understood as two persons stay together just only to fulfil their sexual desires towards each
other. Next to that come kinship and any other relations.

But practically the word live-in-relationship has gained much wider interpretation by
various authorities, one of which is courts. Live-in-relationship in India is not considered as
legal and no where it is recognized under any law as a lawful act directly. It is also
considered socially and morally wrong. The culture of India do not permits any person to live
resembling as husband and wife without solemnization of a valid, lawful, ritualistic, cultural
and traditional procedures of marriages. But as we know society is not static and it goes on
changing, as we all know, change is the law of nature, therefore it has already begin to
recognize the concept of live-in-relationship but only by those sect who either commits such
or in whose any of the relatives had done such. The Honble Courts such as The Supreme
Court (SC) and High Courts (HCs) in their various judicial pronouncing held live-in-
relationship legal, with respect to rights of woman/wife, age of majority as well as legal age
of marriage, free consents by the parties willing to live together in such relationship,
voluntarily cohabitation sharing same households etc. but this also does not mean that every
live-in-relationship shall be recognized and held legal.

Critics consider live-in-relationship as a disease to Indian society. As such concept

has been devolved from western culture and is not suitable for Indian society as it affects the
marriage procedure which also binds a person to follow the principle of one woman one
life, thus not affecting the life of any other woman. This practise also affects the psychology
of a person and such person than in any amount will not be satisfied with a single person as
there is no restriction in live-in-relationship to live with the same partner for the whole of life.
It is a type of informal marriage. It is therefore not accepted by society and which is

1
The Concise Oxford Dictionary of Current English, Pg. 693, Ed.- Eighth 1990.
2
The Concise Oxford Dictionary of Current English, Pg. 1013, Ed.- Eighth 1990.
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 Code of Criminal Procedure

considered as social and moral wrong, thus, disentitling a person to get maintenance taking
the ground of live-in-relationship.

Including self opinion over the topic, I strictly oppose the concept of live-in-
relationship as well as obtaining maintenance on the ground of such relationship, as no
personal laws recognize the concept of live-in-relationship and recommends there under any
remedy for such person if the other person departed the other. Even the law of land do not
permits such practises of living together directly.

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 Code of Criminal Procedure

INTRODUCTION
Live-in-relationships in various countries are either recognized as it exists or its
finding recognition via implied provision of different statues that protect property rights,
housing rights. Many countries provide for live-in-relationship contracts in which partners
can determine their legal rights. The law introduced in 1999 in France makes provision for
civil solidarity pacts allowing couples to enter into union and be entitled to same rights as
married couples in such areas as income tax, inheritance, housing and social welfare. Article
147, of the Family Code, Philippines provides that when a man and a woman who are
capacitated to marry each other, live exclusively with each other ass husband and wife
without the benefit of marriage or under a void marriage, their wages and salaries shall be
owned by them in equal shares and the property acquired by both of them. In the UK, live in
couples does not enjoy legal sanction and status granted to married couple. There is no
obligation on the partners to maintain each other. Partners do not have inheritance right over
each others property unless named in their partners will. The live in relation were conferred
legal sanctity in Scotland in the year 2006 by Family Law (Scotland) Act. Laws in the U.S. as
well do not provide the live-in-relationship couple with the rights as enjoyed by married
couple. But such couples can enter into Cohabitation agreement containing stipulation with
regard to their rights and liabilities. But the laws of Canada, Australia, Ireland and China
recognizes live-in-relationship3.

Live-in-relationship is not a new concept in western countries. There, they are pretty
much habitual of such practises. But when moving towards Indian society we came to know
that still marriages are considered as sacramental and holy. It is a bonding between two souls
and a promise to stay together and support until end. Thus, in a society where the institution
of marriage is recognized by society as well as law of the land, than it will be hard and
difficult to accept the concept of live-in-relationship and apply thereof.

Live-in-relationship is not a new concept in Indian society but now a days it is

spreading its roots largely. Formally they were known as maitray karars in which people of
two opposite sex would enter into a written agreement to be friends, live together and look
after each other4. The expression live-in-relationship had nowhere been defined under any

3
http://www.legalservicesindia.com/article/article/live-in-relationship-in-a-marriage-centric-india-1618-1.html
[acc. at 17:30 on 14/08/2017]
4
http://www.legalservicesindia.com/article/article/live-in-relationship-in-a-marriage-centric-india-1618-1.html
[acc. at 17:35 on 14/08/2017]
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 Code of Criminal Procedure

statute nor is any special or separate law there regarding such. The Indian courts had played
an important role to interpret and provide a definite meaning to the expression live-in-
relationship in various judicial pronouncing. Again they further tried to prescribe and to
cover it under the umbrella of law by providing different rights and duties to the aggrieved
party living in such relationship. Maintenance is one of such remedy, provided to woman or
so called wife in their live-in-relationship, in case, when she is wilfully abandoned by her
husband.

Live-in-relationship thus may be defined as A living arrangement in which an

unmarried couple lives together under the same roof in a long term relationship that
resembles a marriage is known as a live- in-relationship. Thus, it is the type of arrangement
in which a man and woman live together without getting married. This form of relationship
has become an alternate to marriage in metropolitan cities in which individual freedom is the
top priority amongst the youth and nobody wants to get entangled into the typical
responsibilities of a married life.5

Thus it is not clear from the above definition that what will be the exact status of the
person living in live-in-relationship as well as how to determine the rights and duties of such
persons. It generally says that it is a living arrangement in which two persons share a roof for
a long term relationship that resembles marriage. It neither talks for the time period for which
person under such relationship is bound to live together continuously nor any obligations
arising out of such relationship. This form of living together is not recognized by Hindu
Marriage Act, 1955 or any other statutory law. While the institution of marriage promotes
adjustment; the foundation of live-in-relationships is individual freedom. Though the
common man is still hesitant in accepting this kind of relationship, the Protection of Women
from Domestic Violence Act 2005 provides for the protection and maintenance thereby
granting the right of alimony to an aggrieved live-in partner.

At present in India no law deals with the concept of live-in-relationship. But even in
the absence of a specific legislation on the subject, it is praiseworthy that our courts take an
initiative and give certain recognition to such relationships. In earlier cases the court tended
to presume marriage based on the number of years of cohabitation. In the cases prior to

5
http://www.helplinelaw.com/family-law/slri/status-of-live-in-relationships-in-india.html [acc. at 17:55 on
14/08/2017]
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 Code of Criminal Procedure

independence like A Dinohamy v. WL Blahamy6, the Privy Council laid down a broad rule
postulating that where a man and a woman are proved to have lived together as a man and
wife, the law will presume, unless the contrary be clearly proved, that they were living
together in consequences of a valid marriage. The same principle was reiterated in the case
of Mohabhat Ali v. Mohammad Ibrahim Khan7.

After independence, the SC in Badri Prasad v. Dy. Director of Consolidation8,

recognized live-in-relationship as a valid marriage. Later in Patel and others case9, the SC
observed that live-in-relationships are not illegal. The same proposition was upheld in the
case of Tulsa v. Durghatiya10. The further sanction to live-in-relationship was granted by
judgement of SC in 2010 in the S. khushboo vs. Kanniammal & Anr.11 where it was held
that live-in-relationship is permissible only in unmarried major persons of heterogeneous sex

However, this position is not all binding. The Delhi High Court, in a recent case of
Alok Kumar v. State12, observed that a live-in-relationship is a walk in and walk out
relationship. Hence, though more or less uniformity has been exuded in a positive direction
by the court when it comes to live-in-relationships, but law does not cut a clear picture.

Thus, it is clear from the above mentioned cases that in India, courts had played an
important role to recognize the concept of live-in-relationship. But that too is also not enough
to locate the exact position of the persons in live-in-relationship. Whatever is alike cannot be
considered as the same thing to original. As live-in-relationship is considered to be a valid
which resembles as marriage, hence, deriving obligations towards the parties. Prima facie,
Gold and Brass looks identical but they differ in substance and quality. Same way though
live-in-relationship resembles as marriage but both are different. As no law is there to govern
such therefore the courts had interfered and only inorder to recognize the rights, obligations,
remedies in case of breach of arrangements the courts has given it validity.

6
(1928) 1 MLJ 388 (PC)
7
AIR 1929 PC 135
8
AIR 1978 SC 1557
9
(2006) 8 SCC 726
10
(2008) 4 SCC 520
11
JT 2010 (4) SC 478
12
Crl M.C. no. 299/2009
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 Code of Criminal Procedure

LIVE-IN-RELATIONSHIP AND MAINTENANCE

The concept of live-in-relationship is recognized by different judicial pronouncing but
what to be done if the so called husband in such live-in-relationship wilfully abandons his so
called wife. There originates the point of obligations and rights. The aggrieved party, which
generally is a wife, knocks the door of Court to invoke her rights regarding maintenance. As
the court had recognized the validity of live-in-relationship as to that of marriage therefore it
becomes necessary to ensure maintenance to the aggrieved party in such relationship as a
matter of right.

The only concerning issue is to protect the rights of woman in live-in-relationship. As

no law specifically had the provision regarding the maintenance of any person in live-in-
relationship court has taken the step to remove such obstacle. The rights of female partner in
live-in-relationship tend to be secure, credited to the recent statutes and recommendation by
the committees. Courts also display alacrity to protect the rights of female partner in such
relationship as exhibited by judgments given in number of cases. The statues like Protection
of Women from Domestic Violence Act, 2005 protects both in the categories of wife i.e.
relationship by marriage and live in partner i.e. relationship in nature of marriage. However,
as was discussed in D. Veluswami v. D. Patchaimmal, to get the benefits arising from it is
necessary that couple must hold themselves out to society as being akin to spouses.

In June, 2008, The National Commission for Women recommended to Ministry of

Women and Child Development made suggestion to include live in female partners for the
right of maintenance under Section 125 of CrPC. This view was supported by the judgment in
Abhijit Bhikaseth Auti v. State of Maharashtra and others13, This positive decision in
favour of live-in-relationship was also supported by Maharashtra government in October,
2008 when it accepted the proposal made by Malimath Committee and Law Commission of
India which suggested that if a woman has been in a live-in-relationship for considerably long
time, she ought to enjoy the legal status of wife. And once if she acquires the legal status of
wife she is also entitle to get maintenance.

From above discussion, an important observation has been made that to recognize the
right of female partners in live-in-relationship via some statues will have to be accompanied
by changes in laws of succession, adoption, marriage.

13
Crl W.P. no. 2218 of 2007
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 Code of Criminal Procedure

MAINTENANCE RECOGNIZED UNDER DIFFERENT LAWS

Directly, there is no provision regarding the maintenance given to a woman or any
other person in situation of live-in-relationship. The courts in different cases had interpreted
and presumed the status of aggrieved party in live-in-relationship making entitle for
maintenance.

S.24 of Hindu Marriage Act, 1955, talks about Maintenance pendente lite and
expenses of proceedings and S.25 of the same act talks about Permanent alimony and
maintenance. Both the sections had does not recognized this form of living and thus no
maintenance has been prescribed for such type of situation. There the word wife has been
used. Wife has been defined in Cr.PC under S. 125 (1) explanation (b) i.e. Wife includes a
woman who has been divorced by, or has obtained a divorce from, her husband and has not
remarried. This means a legally wedded woman falls under the ambit of wife. Thus if
interpreted literally the sections the woman in live-in-relationship will not come under the
scope of wife. Therefore it will disentitle the woman to get maintenance under such section of
Hindu Marriage Act, 1955.

In Muslim Womens (Protection of Rights on Divorce) Act, 1986, no such rights for
woman who stays in live-in-relationship to get maintenance is mentioned. The said Act does
not recognize such type of practise.

But in Protection of Women from Domestic Violence Act, 2005 in its S.2 (f)
indirectly recognizes the woman in live-in-relationship and in S.20 it talks about monetary
relief. On the order of Magistrate monetary relief may be given to the aggrieved party.

Thus, when observing the provisions mentioned under the above Acts, it can be
concluded that no any law or statute provides for the maintenance of a woman in live-in-
relationship directly.

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 Code of Criminal Procedure

MAINTENANCE RECOGNIZED UNDER CrPC

Chapter IX i.e. Order for Maintenance of Wives, Children and Parents, from S.125 to S.128
deals with the concept of maintenance. The section requires the couple to be a married
couple, woman under marriage i.e. legally wedded wife or a divorced woman or a woman in
course of divorce only than a woman shall be entitle for maintenance subject to S.127(3)
which disentitles a woman to get maintenance. But Honble the Supreme Court had presumed
the couple living together a married couple. Therefore the aggrieved party can claim
maintenance. In support of this an article is published i.e.

Couple living together will be presumed married, Supreme Court rules14

If an unmarried couple is living together as husband and wife, then they would be presumed
to be legally married and the woman would be eligible to inherit the property after death of
her partner, the Supreme Court has ruled.

A bench of Justice MY Eqbal and Justice Amitava Roy said continuous cohabitation of a
couple would raise the presumption of valid marriage and it would be for the opposite party
to prove that they were not legally married.

"It is well settled that the law presumes in favour of marriage and against concubinage, when
a man and woman have cohabited continuously for a long time. However, the presumption
can be rebutted by leading unimpeachable evidence. A heavy burden lies on a party who
seeks to deprive the relationship of legal origin," the bench said.

The court passed the order in a property dispute where family members contested that their
grandfather, who was living with a woman for 20 years after his wife's death, was not legally
wedded to the woman and she was not entitled to inherit the property after his death. They
contended that she was their grandfather's mistress.

Despite the woman failing to prove that she was legally wedded, the court presumed that she
was the legal wife after family members admitted that his grandfather had a relationship with
the woman who was living with them in the joint family.

14
http://timesofindia.indiatimes.com/india/Couple-living-together-will-be-presumed-married-Supreme-Court-
rules/articleshow/46901198.cms [acc. at 07:40 on 17/08/2017]
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"Where a man and woman are proved to have lived together as husband and wife, the law
will presume, unless the contrary is clearly proved, that they were living together in
consequence of a valid marriage, and not in a state of concubinage," the bench said.

"In the fact of the case, there is strong presumption in favour of the validity of a marriage and
the legitimacy of its child for the reason that the relationship is recognized by all persons
concerned," it said.

The court said continuous cohabitation as husband and wife and their treatment as such for a
number of years might raise the presumption of marriage which could be rebutted only if
there were circumstances which destroyed the presumption.

Thus the woman is entitled to get maintenance under Cr.PC.

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COURTS ON MAINTENANCE IN LIVE-IN-RELATIONSHIP

The court through various cases in its judgement had recognized the concept of live-in-
relationship as well as entitling a woman to get maintenance as well.
The court made it clear that if the man has a live-in arrangement with a woman only for
sexual reasons, neither partner can claim benefits of a legal marriage. In order to be eligible
for palimony, a relationship must comply with certain conditions, the apex court said. The
following conditions were laid down by the apex Court:

The couple must hold themselves out to society as being akin to spouses;
They must be of legal age to marry; they must be otherwise qualified to enter into a
legal marriage, including being unmarried;
They must have voluntarily cohabited for a significant period of time.

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CRITICISM

The criticism of such is more stronger than the its positive concept. They are as
follow-

1. Though live-in relationships are a rising trend in urban India, our society is yet to
accept it open-heartedly. It is still seen as taboo, especially by the elderly people.
Often such couples are seen as social deviants, which mean that they are berated,
criticised and often harassed for their individual choice. A society that divides couples
in the name of caste, class and religion, cannot be expected to see a live-in
relationship sans a harsh judgemental perspective.
2. The very advantage of being in a live-in relationship, is its biggest disadvantage as
well, which is lack of commitment. Anything from a small fight, disagreement, or a
misplaced question can see either of the partners walking out of the relationship.
Agrees Amrita Gyan, who got married to her live-in partner fearing this uncertainty
factor that the live-in added to their relationship. She says, "When a couple is married
they will make every possible effort to save their relationship and seek solutions to
problems and misunderstanding before choosing to split up." It is true that in a live-in
relationship where there is no financial, social and legal binding, so the door out is
always open for the couples.
3. Biologically, socially and emotionally women are at the worst receiving end if a live-
in relationship fails to work out. In our society, where patriarchal norms rule in the
social diktats, women are the ones who bear the worst burns of stepping out of
conventions. It becomes difficult for them to find a good and understanding spouse
after being in a live-in relationship with someone else. Also, women loose time with
their biological clocks ticking away when a marriage or its initiation is delayed.
4. The children who are born in a live-in relationship are considerably affected by it.
First of all, they may develop a lack of respect for rules and norms. And they also
harbour an edge of mistrust in their hearts, especially if their parents separate.
Secondly, after separation the father of the child holds no explicit legal ground to
claim any custodial rights. It mostly depends upon the mother of the child to decide
on the fathers claims. Lastly, a child born out of a live-in relationship has no right to
claim his or her fathers inheritance. Since their parents relationship is void of all
legal bindings, it also means that they have no legal grounds to claim inheritance.

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SELF OPINION

Live-in-relationship now days are gaining much attraction in contemporary society.

Change is required, as it is a constant law of nature as well, but what is the benefit of such
change which deems to have a negative impact over the life of people. We Indians always try
to imitate the westerns either in terms of life styles, food styles, fashion etc. but we never tend
to adopt it in its true sense. We only try to imitate that. Moreover, we have always adopted
the negative activities much before than comparison to positive activities such as fast foods,
live-in-relationship etc. Here, the person finds difficult in maintaining the lawful relationship
and we are emphasising on live-in-relationship and maintenance thereupon. Few opinions
against of live-in-relationship had been drawn by observing the earlier mentioned facets of
the concept. They are mentioned below point wise-

1. Live-in-relationship is not the origin of Indian society. Majorly the principle of

one woman one life is followed. Lawful marriage is recognized as it helps to
establish a deep understanding and bonding in between the partners till the end of
life.
2. No time bar in live-in-relationship. As any of partner is at liberty to drop the other
at any point of time.
3. The advocates of such concept support it as getting a pre-marital experience in
order to understand the relationship better which will prove to be beneficial after
marriage to establish a good bonding between the spouses.
4. Live-in-relationship is selfish in nature.
5. The ultimate aim of such relationship is to get sexual satisfaction or to establish a
sexual relationship. Partners in such relationship are not serious about their
relationship. If not satisfied by any of partner the other will abandon his/her
partner.
6. Psychological aspect is that a person will not be able to establish a permanent
relationship with only a single person in his/her life time.

The above opinion does not mean that, I oppose the judgement or decision related to
validating the live-in-relationship by Honble Courts. The courts have favoured it in point of
rights and liabilities. But according to me, what is not prescribed in law should not to be
approved by the Honble Courts also and thus no maintenance to be provided in such. The
situation may be different if any separate law was there regarding live-in-relationship.

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CONCLUSION

The basic conclusion draws from the study is that, there is immediate requirement to
bring legislation on live-in-relationship in order to deal with each and every aspect of such or
amendment is required to give effect in existing law with regard to such relationship. Live-in
relationships in India have still not received the consent of the majority of people. They are
still considered a taboo to the Indian society. The majority of the people consider it as an
immoral and an improper relationship. At present there is no specific legislation that deals
with concept of live in relationship and the rights of the parties and the children of the live in
partners. It was a very unambiguous concept until the Supreme Court of India took the
initiative and declared that live in relationship though considered immoral but it is not illegal.

Through its various decisions the judiciary has tried to accord legality to the concept and
protect the rights of the parties and the children of live in couples. But at present there is a
need to formulate a law that would clarify the concept. There should be clear provisions with
regard to the time span required to give status to the relationship, registration and rights of
parties and children born out of it. The utmost need of the hour is to secure the future of the
children born to live in couples. The steps taken by the judiciary are indeed welcoming and
pragmatic in approach. Though the live in relations provide the individuals individual
freedom but due to the insecurity it carries it with, there needs to be a law to curtail its
disadvantages.

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REFERENCES

BOOKS REFERRED

Ratanlal & Dhirajlal, The Code of Criminal Procedure.

R. V. Kelkars, Criminal Procedure.

STATUTE REFERRED

Code of Criminal Procedure, 1973

Hindu Marriage Act, 1955
Muslim Womens (Protection of Rights on Divorce) Act, 1986
Protection of Women from Domestic Violence Act, 2005

CASES REFERRED

A Dinohamy v. WL Blahamy, (1928) 1 MLJ 388 (PC)

Abhijit Bhikaseth Auti v. State of Maharashtra and others, Crl W.P. no. 2218 of 2007
Alok Kumar v. State, Crl M.C. no. 299/2009
Badri Prasad v. Dy. Director of Consolidation, AIR 1978 SC 1557
Mohabhat Ali v. Mohammad Ibrahim Khan, AIR 1929 PC 135
Patel and others case, (2006) 8 SCC 726
S. khushboo vs. Kanniammal & Anr., JT 2010 (4) SC 478
Tulsa v. Durghatiya, (2008) 4 SCC 520

WEBSITES REFERRED

www.google.com
www.helplinelaw.com
www.ndtv.com
www.huffingtonpost.in
www.onlymyhealth.com
www.legalservicesindia.com
timesofindia.indiatimes.com

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